This note is a general briefing on the 2025 tax reform package as it stood in September 2026. It is not legal, tax or accounting advice. Thresholds, NRS practice and the e-invoicing calendar continue to move. If the file is yours, write to the desk.
On 1 January 2026 a set of 2025 Acts recast federal tax in Nigeria. FIRS is no longer the administrator. The Nigeria Revenue Service is. Company income tax for firms that do not qualify as small companies is 30 percent, plus a new 4 percent Development Levy on assessable profits. Professional services — including accounting firms — do not get the 0 percent small-company rate, whatever their turnover.
Four Acts, one start date
The package is usually described as four statutes, in force from 1 January 2026:
- the Nigeria Tax Act 2025 — the charging rules, including company tax, the Development Levy and the small-company definition used for CIT;
- the Nigeria Tax Administration Act 2025 — how tax is administered, filed and enforced;
- the Nigeria Revenue Service (Establishment) Act 2025 — NRS in place of FIRS;
- the Joint Revenue Board of Nigeria (Establishment) Act 2025 — coordination with the states.
Existing TINs continue. The brand on the letterhead changed. The obligation to file did not.
What NRS is — and is not
NRS is the federal tax authority. State internal revenue services still exist. VAT, CIT, withholding tax and the federal pieces of PAYE sit with NRS. Pay-as-you-earn for FCT and the states still has a state-shaped edge. Transfer pricing and international assignee files have not been “simplified away”; they have a new administrator.
Rev360 is the filing environment that replaced TaxProMax. If your last return still lives in an old portal login, that is a practical problem for this close — not a philosophical one.
Company tax: 30 percent, plus 4 percent
The old three-tier CIT structure (small / medium / large at 0 / 20 / 30 percent) is gone. In its place:
- qualifying small companies: 0 percent CIT, and they are out of the Development Levy and, as the charging rules are written, out of company CGT on the same profits;
- every other company: 30 percent CIT on profits, plus a Development Levy of 4 percent of assessable profits.
The Development Levy consolidates several older sector levies (including the tertiary education tax and IT / NASENI-style charges) into one line. It is not optional, and it is not VAT. Non-resident companies are generally outside it; small companies that actually qualify are outside it. Everyone else should budget for it as a second federal line next to CIT.
Capital gains for companies that are not small companies are charged at 30 percent under the new code. In-scope multinational groups also need to consider the 15 percent minimum effective tax rate. That is a different file from a domestic close.
The small-company line — do not self-certify from a blog
To be a small company for CIT, the tests are roughly: turnover at or under a statutory naira line, fixed assets at or under ₦250 million, and not carrying on professional services. All of them, together.
The turnover line is the part commentators still fight over. Some readings of the Nigeria Tax Act put it at ₦50 million. Other readings, and some administrative practice, talk about ₦100 million — in places using the language of a “small business” under the administration Act, which is not automatically the same thing as a “small company” for CIT. As at September 2026 there is no substitute for reading the sections against the return you are about to file.
Two things are not in dispute, and they are the ones boards get wrong:
- professional services are excluded from the 0 percent CIT rate regardless of size;
- even a company with nil CIT still has to file.
Professional services are out
Accounting, audit, tax, legal, medical, architectural, engineering and management consultancy — the list is not a marketing category. It is a charging category. A professional practice with ₦20 million of fees is still in 30 percent CIT and the 4 percent levy. Do not build a 2026 budget on the assumption that “we are small, so we are at 0 percent.”
That exclusion is why this firm’s own tax position, and that of most of the people who read this briefing, is not the small-company story in the newspapers.
VAT, PAYE, e-invoicing
VAT remains 7.5 percent. Personal income tax now shields the first ₦800,000. E-invoicing is being phased; treat the calendar as NRS’s, not as a rumour on a webinar. We will not put a go-live date on this page that we cannot stand behind in a letter.
What to do this quarter
- Confirm the entity’s TIN still works in Rev360, and who in finance owns the login.
- Model CIT at 30 percent plus the 4 percent Development Levy unless you have a written position that the company is small — and that it is not a professional-services firm.
- Do not claim the 0 percent rate because turnover “feels like” ₦50 million or ₦100 million. Have the tests applied to the last audited figures.
- If NRS or a state IRS has already written, bring the letter. Correspondence is a file, not a mood.
- If IFRS 18 or ICFR is landing in the same year, say so. Tax and reporting should not be two surprises.
Questions we are asked
- Did my TIN change when FIRS became NRS?
- No. Existing Tax Identification Numbers continue. The administrator is now the Nigeria Revenue Service. Filings and correspondence run through NRS systems, including Rev360.
- Do professional-services firms get 0% CIT if turnover is small?
- No. Professional services — including accounting, audit, legal, medical, engineering and consultancy — are excluded from the small-company 0% CIT rate, regardless of turnover or assets. They remain in the standard 30% CIT plus 4% Development Levy.
- Is the small-company turnover line ₦50 million or ₦100 million?
- Commentators disagree, because the 2025 acts do not use one phrase in one place. Do not self-certify from a blog. Have the file reviewed against the Act, NRS practice and the returns you actually file.